Chatmon v. State
2015 Ark. 417
| Ark. | 2015Background
- Rolandis Chatmon was convicted of three counts of aggravated robbery and one count of theft; sentenced as a habitual offender with firearm enhancement to three consecutive life terms plus 360 months.
- Chatmon appealed; this Court affirmed on direct appeal (Chatmon v. State, 2015 Ark. 28).
- Chatmon filed a pro se petition asking this Court to reinvest jurisdiction in the trial court so he could pursue a writ of error coram nobis.
- He alleged two principal grounds: judicial bias (based on the trial judge’s later bribery conviction and certain in-court/nontrial conduct) and multiple forms of prosecutorial misconduct (perjured testimony, fabricated/mishandled evidence, and suppression of investigative reports/transcripts).
- The Court explained coram nobis is an extraordinary, narrow remedy available only for fundamental errors not discoverable or raised at trial (four recognized categories), and reinvestment is required before the circuit court may consider the petition when the record remains here.
- The Court denied the petitions, holding Chatmon’s allegations were conclusory, largely addressed at trial or on appeal, or failed to demonstrate a reasonable probability of a different outcome.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial bias by trial judge | Judge later convicted of bribery and showed bias by not ruling on motion for new counsel and other conduct; appearance of favoritism to prosecution | Alleged actions were known/decided at trial or on record; no showing of actual bias or prejudice; issues could have been raised on appeal or by other postconviction remedies | Denied — appearance alone insufficient; no reasonable probability of different result if unbiased judge had presided |
| Prosecutorial suppression of evidence (Brady) | Prosecution withheld reports/transcripts (Chambers statement; Monette Solomon interview) that would have exonerated or impeached witnesses | Defense knew of Chambers’ statement; no proof a transcript existed or that suppressed materials were material; claims are conclusory | Denied — allegations not sufficiently specific or shown to be material; defense was aware of relevant matters; no reasonable probability of different outcome |
| Use of perjured/fabricated/mishandled evidence | Prosecution used perjured testimony, fabricated evidence, failed to perform testing on wallet, misrepresented other-crimes evidence at sentencing | These are factual issues either adjudicated at trial or cognizable in other proceedings; coram nobis does not correct adjudicated trial facts or issues that could have been raised at trial | Denied — such claims are not proper coram-nobis grounds and were either adjudicated or available earlier |
| Reinvesting jurisdiction & coram nobis standard | Chatmon seeks leave to proceed in circuit court | Court must determine if allegations are reasonable and likely true such that the petition appears meritorious before reinvesting jurisdiction | Denied — allegations fail the reasonable-probability/meritorious-attack threshold for coram nobis relief |
Key Cases Cited
- Noble v. State, 2015 Ark. 141, 460 S.W.3d 774 (standard for reinvesting jurisdiction and coram nobis categories)
- Isom v. State, 2015 Ark. 225, 462 S.W.3d 662 (court reviews reasonableness/probability of truth before granting reinvestment)
- White v. State, 2015 Ark. 151, 460 S.W.3d 285 (coram nobis is extraordinary; remedy narrow)
- Clark v. State, 358 Ark. 469, 192 S.W.3d 248 (writ for facts unknown/hidden at trial)
- Westerman v. State, 2015 Ark. 69, 456 S.W.3d 374 (presumption of validity; claims cognizable elsewhere not for coram nobis)
- Turner v. State, 2012 Ark. 357 (must show reasonable probability of different result from unbiased judge)
- Penn v. State, 282 Ark. 571, 670 S.W.2d 426 (court not required to accept petition allegations at face value)
- Barker v. State, 2010 Ark. 354, 373 S.W.3d 865 (suppression of material exculpatory evidence falls within coram-nobis category)
- Bass v. State, 191 Ark. 860, 88 S.W.2d 74 (coram nobis does not correct adjudicated trial facts or false trial testimony)
- Howard v. State, 2012 Ark. 177, 403 S.W.3d 38 (issues that could have been raised at trial are not coram-nobis grounds)